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Michigan Department of Education Child and Adult Care Food Program (CACFP)

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Michigan Department of Education Child and Adult Care Food Program (CACFP)
Michigan Department of Education
Child and Adult Care Food Program (CACFP)
Family Day Care Home Sponsor
Administrative Review
Sponsor:
❒ Announced
Date
Agreement #
❒ Unannounced
❒ Overpayment disregard used
Number of homes approved as of 9/30/__
Number of homes approved as of _____________________
(Date of review)
Number reviewed
A. General Information
Recordkeeping
1. All records are available to support claims for 3 years plus the
current year. [7 CFR 226.10(d)]
❒ Y
❒ N
2.
The sponsor distributed information about the benefits of the
CACFP to all parents. [7CFR 226.16(b)(5)]
❒ Y
❒ N
3.
The application and all supporting documentation submitted
to MDE is on file. [7 CFR 226.15(e)]
❒ Y
❒ N
4.
Sponsor ensures that the WIC poster is posted at sites or WIC
materials are given to parents/guardians. [7 CFR 226.6(r)]
❒ N/A ❒ Y
❒ N
5.
Attach a copy of the institution page. Verify
information and note changes below.
6.
The sponsor has written recruitment and outreach practices
as part of their management plan.
❒Y
❒ N
7.
The written recruitment and outreach practices are being
implemented.
❒Y
❒ N
Comments
B.
Board of Directors and Oversight – if applicable
1.
Number of board members.
2.
Board members related to each other or any other staff.
❒ N/A ❒ Y ❒ N
If yes, list names, positions, and relationships:
3.
Conflict of interest policy includes conflict disclosure and
procurement.
Page 1 of 13
❒ N/A ❒ Y ❒ N
4.
List dates of the three most recent board meetings and note whether CACFP oversight
is documented in the minutes.
Meeting Date
CACFP Oversight Documented
□
□
□
Yes
Yes
□
□
□
No
No
5.
Yes
No
Schedule of board meetings reviewed.
❒ N/A ❒ Y ❒ N
6.
Board has oversight of administrative and financial decisions.
❒ N/A ❒ Y ❒ N
7.
Board has authority to hire and terminate executive director.
❒ N/A ❒ Y ❒ N
C.
1.
Training
The sponsor conducted training for all key staff prior to CACFP
operations on: (new facilities only) [7 CFR 226.16(d)(2)]
❒ meal patterns ❒ meal counts
❒ N/A ❒ Y ❒ N
❒ claims submission and claim review procedures
❒ recordkeeping requirements
2.
❒ the sponsor’s reimbursement system
The sponsor conducted annual CACFP training for all key
staff on: [7 CFR 226.16(d)(3)]
❒ meal patterns ❒ meal counts
❒ Y ❒ N
❒ claims submission and claim review procedures
❒ recordkeeping requirements
3.
❒ the sponsor’s reimbursement system
The sponsor trained staff with monitoring responsibilities
annually on: [7 CFR 226.15(e)(14)]
❒ meal patterns ❒ meal counts
❒ claims submission and claim review procedures
❒ recordkeeping requirements
4.
❒ the sponsor’s reimbursement system
Training documentation includes: [7 CFR 226.15(e)(12)]
❒ date(s) ❒ location(s) ❒ topic(s) ❒ names of participant(s)
Comments
D.
Provider Training
1. The sponsor conducted training for each provider prior to CACFP operations on:
[7 CFR 226.16(d)(2)]
❒ meal patterns
❒ meal counts
❒ claims submission and claim review procedures
❒ recordkeeping requirements
❒ the sponsor’s reimbursement system
❒ civil rights requirements
Page 2 of 13
❒ Y ❒ N
2. The sponsor conducted annual CACFP training for each provider on:
[7 CFR 226.16(d)(3)]
❒ meal patterns
❒ meal counts
❒ claims submission and claim review procedures
❒ recordkeeping requirements
❒ the sponsor’s reimbursement system
❒ civil rights requirements
3. Training documentation includes: [7 CFR 226.15(e)(12)]
❒ date(s) ❒ location(s) ❒ topic(s) ❒ names of participant(s)
Comments
E.
Procurement [7 CFR 226.21, 7 CFR 226.22]
1.
Annual vendor selection documentation is available to support
the small purchase method for all purchases less than
$150,000.
❒ N/A ❒ Y
❒ N
2.
A competitive bid process is used for purchases over
$150,000.
If yes, documentation is available to support the competitive
bid procedure.
❒ N/A ❒ Y
❒ N
❒ Y
❒ N
If applicable, contracts were submitted to MDE.
❒ N/A ❒ Y
❒ N
For contracted services, the terms of the contract were
followed.
❒ N/A ❒ Y
❒ N
Written Code of Conduct and performance available for
staff engaged in award and administration of contracts.
❒ N/A ❒ Y
❒ N
❒ N/A ❒ Y
❒ N
❒ Y
❒ N
3.
4.
Comments
F.
1.
Financial Management
Sponsor obtained audit, if required.
If applicable, the sponsor implemented corrective action(s) to
any findings.
2.
The sponsor has written procedures for financial management.
❒ Y
❒ N
3.
The written procedures for financial management are being
adhered to.
❒ Y
❒ N
4.
Payments to providers are made within 5 working
days of receipt from MDE. [7 CFR 226.16(h)]
❒ Y
❒ N
5.
Administrative earnings and meal reimbursement money are
tracked separately in sponsors’ financial system.
6.
No checks were outstanding for more than two months.
If no, list on worksheet.
Page 3 of 13
❒ Y
❒ N
❒ Y
❒ N
7.
Number of insufficient funds or late fee charges during the
four month period beginning with the month before the
review month.
8.
Describe any check clearing irregularities:
Comments:
G.
Administrative Costs and Claim
[7 CFR 226.15(e), 7 CFR 226.14(a)]
Verify the accuracy of figures reported and supporting documentation for test month selected
Item
Amount Claimed
(✓ )
if okay
If not checked, note problem
Salaries
Benefits
Travel
Occupancy
Contracted Services
Supplies
Training
Equipment
Other
Total
1.
2.
MDE monthly approved budget.
Administrative costs claimed for
3.
Documentation was available to support all costs reported on
the claim. List discrepancies on worksheet.
❒ Y
❒ N
4.
A copy of the claim is on file.
❒ Y
❒ N
5.
Documentation is available to verify receipt of CACFP
reimbursement payments received from MDE.
❒ Y
❒ N
6.
List any questionable payments on worksheet.
7.
YTD administrative costs are within approved YTD budget.
❒ Y
❒ N
8.
YTD administrative costs are less than 30% of the total
of administrative payments and meal payments to providers.
❒ Y
❒ N
9.
If it appears that costs exceed reimbursement over an extended period, identify the
other sources of income available to the sponsor to meet financial liabilities incurred in
excess of reimbursement.
10.
The sponsor only receives CACFP funding. If sponsor receives
public or private funding in support of its CACFP operation,
explain below.
(test month)
11. The sponsor’s non-profit food service report is within its 3
month operating balance. [FY 2005 Operational Memo #34]
Page 4 of 13
$
$
❒ Y
❒ N
❒ Y
❒ N
12. The sponsor has a board-approved written employee
compensation policy.
❒Y
❒ N
13. The sponsor has a current cost allocation plan.
❒ N/A ❒ Y
❒ N
14. The sponsor is following their cost allocation plan.
❒ N/A ❒ Y
❒ N
15. If this review is a follow-up review and over-claims were assessed at the previous
review, what funds did the sponsor use to cover the amount deducted for the over-claim?
______________________________________________________________________
______________________________________________________________________
Comments:
H.
1.
2.
Tiering/Income Eligibility/Enrollment
The sponsor has implemented the tiering system described in
the Management Plan for identifying and determining Tier 1
and Tier 2 homes.
A system is in place to ensure that Tier 1 determinations are
made:
 Each year for income eligibility forms
❒ Y
❒ N
❒ Y
❒ N

Every five years for school data
❒ Y
❒ N

When new census data is issued
❒ Y
❒ N
3.
The sponsor has informed Tier 2 providers of the option of
identifying income eligibility children in their care.
❒ Y
❒ N
4.
The sponsor makes income eligibility forms available to
households of children enrolled in Tier 2 homes at the
provider’s request.
❒ Y
❒ N
5.
Completed income eligibility forms are sent directly from the
households to the sponsor or a consent is signed by the
household if the provider sends the IES to the sponsor on
the household’s behalf.
❒ Y
❒ N
6.
The sponsor maintains the confidentiality of income eligibility
information.
❒ Y
❒ N
7.
Number of providers:
Tier 1 (Area Eligible) _________
Tier 1 (Income)
_________
Tier 1 (Census)
_________
Tier 2 (Mixed)
_________
Tier 2
_________
TOTAL
_________
Total approved Provider Income Eligibility Statements
Total approved Household Income Eligibility Statements
Total approved Income Eligibility Statements
8.
9.
Percentage of Provider Income Eligibility Statements to review
Number reviewed by MDE
Percentage of Household Income Eligibility Statements
to review
Number reviewed by MDE
Page 5 of 13
___
___
%
%
10. Documentation is on file to support Tier 1 reimbursements for
the following categories:
Tier 1 – area eligible based on school data
❒ Y
❒ N
Tier 1 – area eligible based on census data
❒ Y
❒ N
Tier 1 – eligible based on income, including verification
❒ Y
❒ N
Tier 2 - provider with income eligible day care children
❒ Y
❒ N
Comments:
I. Enrollment [7 CFR 226.15(e)(2) and 226.17(b)(8)]
(Not applicable for at-risk programs and emergency shelters)
1.
Current enrollment documentation is on file for each participant
claimed. If no, see worksheet.
2.
Enrollment forms are updated annually.
3.
Enrollment forms contain:
❒ N/A ❒ Y ❒
N
❒ N/A ❒ Y ❒
N
❒ Participant’s name
❒ Dated participant’s, parent, or legal guardian signature
❒ Normal days and hours in care
❒ Meals normally received while in care
Comments _________________________________________________
___________
___________________________________________________________
____________
________________________________________________________________________
J. Sponsor Monitoring [7 CFR 226.16(d)(4)(i-viii)]
Previous fiscal year:
Number of active homes on September 30
_______
Number of home reviews
_______
Current fiscal year:
Number of active homes as of date of review
Number of home reviews
_______
_______
Answer the following questions from:
 A list of reviews for the current and previous fiscal year by facility listing the review
date, unannounced or announced and meal observed;
 Review forms conducted for current and previous fiscal years; and
 Review criteria in CACFP FY2005 Memo #41.
1.
The sponsor reviewed each site the required number of times
per year.
Sites operating 12 months – 3 reviews
Sites operating 9 months or less – 2 reviews
Sites operating 4 months or less – 1 review
❒ Y
❒ N
2.
Each facility received at least two unannounced reviews
last year.
❒ Y
❒ N
Page 6 of 13
3.
At least one unannounced review included a meal
observation.
4.
For new facilities: At least one review was made during the
facility’s first 4 weeks of CACFP operation.
5.
There were no more than 6 months between reviews.
6.
❒ Y
❒ N
❒ N/A ❒ Y
❒ N
❒ Y
❒ N
Monitoring reviews were documented.
❒ N/A ❒ Y
❒ N
7.
The monitoring forms were complete.
❒ N/A ❒ Y
❒ N
8.
Facility reviews assess compliance with:
❒ meal patterns
❒ menu/meal records
❒ enrollment forms
9.
❒ licensing or approval
❒ attendance at training
At facility reviews, the sponsor assesses whether each
facility has corrected problems noted on previous reviews.
❒ N/A ❒ Y
❒ N
10. A reconciliation of the facility’s meal counts with enrollment
and attendance records for a 5 day period is conducted at
each review.
❒ Y
❒ N
11. Facility review averaging is used. If yes:
❒ Y
❒ N
 An average of 3 reviews per facility are conducted;
❒ Y
❒ N

❒ Y
❒ N
❒ Y
❒ N
❒ N/A ❒ Y
❒ N
14. Did the sponsor perform an adequate number of reviews of
each meal type claimed by its facilities?
❒ Y
❒ N
15. Does the sponsor have a review system that ensures
variability in the timing of monitoring visits?
❒ Y
❒ N
16. Is the sponsor in compliance with the monitor staffing ratios
in 226.16(b)(1)?
❒ Y
❒ N
If a facility receives two reviews in one year, the next
review is conducted within nine months.
12. If a facility was seriously deficient, the next review was
unannounced.
13. Does the sponsor have a review system which ensures the
monitoring of all meal types claimed by the facilities?
Number of facilities _____
Number of FTE monitors _____
17. Number of homes reviewed by MDE with no findings.
_______________
18. Number of homes reviewed by MDE with findings but no
serious deficiencies.
19. Number of homes reviewed by MDE with serious deficiencies.
20. Were the findings from the reviews corrected?
Page 7 of 13
❒ Y
❒ N
Comments
K.
Provider Serious Deficiencies
1. The sponsor complied with the serious deficiency,
suspension, and termination requirements in 226.16(l).
❒ Y
❒ N
2.
The sponsor initiates some type of provider performance
standard and moves on a non-compliance issue into the SD
process when there is a repeat finding or the finding is
flagrantly out-of-compliance.
❒ Y
❒ N
3. The sponsor enforces the 30-day deadline for providers’
completion of corrective action in response to a notice of SD.
4. The sponsor promptly moves to issue a Notice of Proposed
Termination and Disqualification (NPTD) when corrective action
is not complete and permanent.
❒ Y
❒ N
❒ Y
❒ N
5. The sponsor ensures that each serious deficiency action
initiated is either corrected, or the provider is terminated for
cause and disqualified.
❒ Y
❒ N
6. The sponsor makes appropriate decisions regarding the
acceptance of particular corrective actions to resolve the
providers’ SD, especially in cases involving the submission of
false or fraudulent claims.
❒ Y
❒ N
7. Number of household contacts made.
#_____________
8. The sponsor conducted household contacts in accordance with
the MDE household contact procedure.
❒ Y
❒ N
Comments
L.
Provider Appeals
1. Number of provider appeals requested in FY ____
#_____________
2. Number of provider appeals held in FY ____
#_____________
3. Sponsor is utilizing MDE Appeal Procedures
❒ N/A ❒ Y
❒ N
❒ N/A ❒ Y
❒ N
4. If no, describe the process the sponsors uses.
_____________________________________________________
_____________________________________________________
5. If applicable, the sponsor’s appeal process was followed.
Page 8 of 13
6. Name(s) of hearing official(s) ______________________________________________
______________________________________________________________________
7. Describe the official’s qualifications __________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
8. Describe the official’s relationship with the SO and/or staff and any less than arms length
transactions _____________________________________________________________
_______________________________________________________________________
_______________________________________________________________________
_______________________________________________________________________
9. Describe how hearing official(s) are trained at least annually on CACFP regulations and
guidance _______________________________________________________________
_______________________________________________________________________
_______________________________________________________________________
_______________________________________________________________________
10. Review 3 appeals files. Summarize findings: _________________________________
_______________________________________________________________________
_______________________________________________________________________
_______________________________________________________________________
M.
Provider File Maintenance and Claim Processing
Number of files reviewed
Provider File Maintenance Summary
Items Reviewed
Number
Provider Name(s)
Missing Application
Missing Sponsor/Provider Agreement
Missing IES, if applicable
Incorrectly classified IES
Missing Monitoring Review Forms
Missing Documentation to Support Tier
Status
Missing License/Registration Number
Items Reviewed
Number
Provider Name(s)
Missing Name, Address, Phone Number
Missing Signature of Provider
Missing Enrollment Form signed by
parents/each child claimed
Missing Meal Attendance Recorded by
date and meal type by child
Missing Verification for holiday/weekend
meals
Missing Daily Infant Menus to support
meals claimed
Missing Daily Menus to Support Meals
claimed
Number of Provider reviews/monitoring
visits not conducted within required
timeframe
Page 9 of 13
Number of reviews monitored for correct
variety of milk
Number of reviews monitored for
availability of water
Number of Incorrect Tier Determinations
Number of Meal Times not approved by
Sponsor
Number of Meal Times not the same as
approved by Sponsor
Number of Providers who did not record
meal attendance by name
Number of Providers with incomplete
enrollment forms
Number of Providers who did not update
enrollment forms annually
Number of Providers claiming children not
within age limits
Number of Providers claiming own
children when other day care children not
present and claimed
Number of Providers claiming more than
allowable meals/snacks per child per day
Number of Providers not within DHS
capacity
Number of Providers claiming more than
28 days in February, or 30 days in Sept.
April, June and Nov
Number of Providers with few or no
absences
Number of Providers with total number of
meals/snacks counted incorrectly
Number of Providers submitting menu
different than sponsor monitor observed
Number of Providers submitting menu
different that MDE monitor observed
Items Reviewed
Number of Providers whose menus did not
meet meal pattern requirements
Number of Providers Claim Value did not
match check register
Number of Providers Reimbursed for
meals/snacks not approved by
sponsor/MDE
Number of Providers whose payments
were not made within 5 working days of
receipt of USDA funds
Number of Providers who should have
been declared SD but were not
Number of Providers who should have had
Household contacts conducted but did not
Number of Checks that did not clear the
bank
Number
Page 10 of 13
Provider Name(s)
1.
Describe how the sponsor notifies the provider of problems identified during worksheet
processing such as non-reimbursable meals, claiming more than the allowable number
of meals per child per day, etc.
2.
The sponsor implements the menu and worksheet processing
system approved in the Management Plan.
❒ Y
❒ N
3.
The sponsor’s edit system used during worksheet processing
insures accurate provider reimbursement.
❒ Y
❒ N
4.
The sponsor uses the following systems to process claims:
Check all that apply
❒ Manual ❒ Accutrack ❒ Web Based ❒ Minute Menu
❒ Y
❒ N
❒ Y
❒ N
5.
❒ Other-describe: _________________________________
The edit system(s) detect: [7 CFR 226.10(c)(1)(2)]
 Unapproved meals

Maximum number of meals by multiplying enrollment
by number of approved meals by number of operating
days
Comments
N.
Civil Rights [FNS Instruction 113-1, 7 CFR 226.6(m)(1), 7 CFR 226.6(b)(4)(iv)]
1.
Ethnicity and race data is collected, complied and compared
annually for program participants.
❒ Y
❒ N
2.
All potentially eligible persons and households have an
equal opportunity to participate in the CACFP.
❒ Y
❒ N
3.
The USDA “And Justice for All” poster is displayed in a
conspicuous location.
❒ Y
❒ N
4.
The USDA nondiscrimination statement is on all materials such
as applications, pamphlets, forms or other program materials
distributed to the public and on web sites.
❒ Y
❒ N
5.
All CACFP materials distributed to the public and on websites
reflect diversity based on race, color, national origin, age,
sex, and disability.
❒ Y
❒ N
6.
The institution has a civil rights complaint procedure.
❒ Y
❒ N
7.
Civil rights complaints are being handled appropriately.
❒ N/A ❒ Y
❒ N
8.
Staff received civil rights training in the
❒ Collection and use of data
❒ Effective public notification systems
❒ Complaint procedures
❒ Compliance review techniques
❒ Resolution of noncompliance
❒ Customer service
following areas:
❒ Requirements for reasonable
accommodations of persons with
disabilities
❒ Requirements for language assistance
❒ Conflict resolution
Page 11 of 13
9.
CACFP information is made available to potentially eligible
persons, CACFP participants, and community organizations to
reach potentially eligible populations.
❒ Y
❒ N
Comments
_
_
O. Previous Reviews & Findings
1. There were findings from previous review.
If yes, list
❒ N/A ❒ Y ❒ N
2. Findings from previous reviews were corrected.
❒ N/A ❒ Y ❒ N
Comments
_
P. Home Review Issues
Q.
Current Issues/Best Practices
Describe innovations, new projects, current concerns or other issues specific to the sponsor.
Page 12 of 13
Summary of Review Findings and Corrective Action Requirements
 No findings  No further corrective action required  Submit all corrective actions to the address below by
 Letter to follow  Overpayment disregard used  Claim amendments required  Application amendments required
Findings must be corrected permanently. Repeated non-compliance will jeopardize future Child and Adult Care Food Program
(CACFP) participation. Submit claim amendments, if required, within 30 days of the date of this notice; otherwise, the
amendments will be processed by the Michigan Department of Education (MDE), deducting the maximum possible.
MDE provided a copy of: (check all that apply)
 Review Form
 Summary of Findings
Institution Signature:
Date:
MDE Signature:
Date:
 Appeal Procedures
If you wish to appeal these findings and/or corrective actions, you must adhere to the CACFP Appeal Procedures.
Send corrective action to:
Michigan Department of Education
Office of School Support Services
Child & Adult Care Food Program
P.O. Box 30008
Lansing, MI 48909
Fax: (517) 373-4022
Phone: (517) 373-7391
S:CACFPStaff/Review Forms/Homes/FDCH Sponsor Administrative Review
Page 13 of 13
Rev. 10/2015
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